In a letter to the leadership of the Senate Finance and House Ways and Means committees, the Medical Imaging & Technology Alliance (MITA) commended the inclusion of language to encourage physician use of imaging appropriateness criteria as part of a broader draft bill to reform the current flawed Sustainable Growth Rate formula for determining Medicare physician payments. However, the Alliance also expressed some concerns, particularly in how the criteria would be developed, shared and used. “A poorly designed policy could ... inadvertently limit appropriate use and negatively impact patient care and outcomes,” MITA warned in the letter.
As the SGR reform framework discussion draft moves forward, MITA asked Senate Finance Committee Chairman Max Baucus (D-Mont) and Ranking Member Orrin Hatch (R-Utah), as well as House Ways & Means Committee Chairman Dave Camp (R-Mich) and Ranking Member Sandy Levin (D-Mich) to consider steps to ensure that appropriate use criteria are developed by physicians in an open and evidence-based manner and include flexibility to avoid promoting “cookie cutter medicine” that does not allow for individualized treatment when needed.
MITA also asked the committee leaders to consider how the criteria would be updated, how clinicians would access the criteria as not all have adopted electronic health records, and how it would be implemented with the current billing and coding systems. From a practical perspective, the ordering physician who would theoretically be the one beholden to imaging appropriate use criteria, is typically not the same as the radiologist who reads the images.
In addition to commenting on appropriate use, MITA also took the opportunity to ask the committee leaders to consider creating an incentive for providers to replace or upgrade older CT systems that do not feature MITA Smart Dose radiation reduction standards. The 13 Medicare reimbursement cuts to advanced diagnostic imaging since 2006 have discouraged providers from investing in new technologies, and as a result, a significant portion of the Medicare population does not have access to modern lower-dose CT scans, MITA noted.
The Alliance also reminded the legislators about the important role of imaging in reducing waste due to missed diagnoses or incorrect treatments, and criticized the Centers for Medicare and Medicaid Services (CMS) for proposing arbitrary changes in payment formula assumptions based upon unscientific data.